Robinson v. Felts
2015 Ark. 174
Ark.2015Background
- Demarcus R. Robinson, pro se, filed a petition for writ of habeas corpus in the Chicot County Circuit Court while incarcerated.
- The circuit court denied Robinson’s habeas petition; Robinson appealed to the Arkansas Supreme Court.
- Robinson argued the Arkansas Parole Board denied him due process by not applying statutory parole-eligibility criteria, not adequately explaining its reasons, and by incorrectly denying parole.
- He did not invoke Act 1780 (actual-innocence statutory route) nor allege the judgment of conviction was facially invalid or that the trial court lacked jurisdiction.
- The Supreme Court reviewed the record and concluded Robinson’s claims do not fall within the narrow grounds for habeas relief under Arkansas law.
- The Court dismissed the appeal as meritless and ruled the pending motions (for an extension of time and for production of documents) moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether habeas relief is available for alleged parole-board errors | Robinson: Parole board violated due process by not applying statutory criteria, failing to explain denial, and wrongly denying parole | State/Respondent: Habeas relief is limited to facially invalid convictions or lack of trial-court jurisdiction; parole claims fall outside habeas scope | Dismissed — parole-board complaints do not state grounds for habeas relief |
| Whether petitioner met statutory pleading/showing requirements for habeas | Robinson: Did not invoke Act 1780; argued substantive parole errors instead | Respondent: Petitioner must plead facial invalidity or lack of jurisdiction (or proceed under Act 1780) and show probable cause | Held — Robinson failed to allege facial invalidity or lack of jurisdiction, so burden not met |
Key Cases Cited
- Sims v. State, 2015 Ark. 41 (per curiam) (appeal of denial of postconviction relief will be dismissed when without merit)
- Hinkston v. State, 2014 Ark. 504 (per curiam) (habeas issues: facially invalid convictions or lack of trial-court jurisdiction justify writ)
- Sims v. Hobbs, 2014 Ark. 503 (per curiam) (burden on habeas petitioner to show lack of jurisdiction or facial invalidity)